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Case 1:11-cr-00007-TSE Document 17 Filed 01/05/11 Page 1 of 3

iNorin ifi;''.;

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IN THE UNITED STATES DISTRICT COURT FOR THE

CIERK. US. DISTRICT COURT


EASTERN DISTRICT OF VIRGINIA ALEXANDRIA, VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA CRIMINAL NO. 1:11CR07

Count 1: 18 U.S.C. § 875(c)


(Interstate Threatening Communications)
AWAIS YOUNIS,

also known as Sundullah "Sunny"


Ghilzai,
Defendant.

JANUARY 2011 TERM - At Alexandria

INDICTMENT

THE GRAND JURY CHARGES THAT:

GENERAL ALLEGATIONS

At all times material to this indictment:

1. The defendant, Awais Younis, also known as Sundullah "Sunny" Ghilzai, lives in

Arlington, Virginia.

2. The victim lives in Louisiana.

3. The victim's father lives in the Washington, D.C. metropolitan area and takes Metro to

work.

4. The defendant, Awais Younis,also knownas Sudullah"Sunny" Ghilzai,and the victim

had communications through Facebook, an online social networking site.

5. The defendant described to the victim in November 2010, a potential attack on the

Metro.
Case 1:11-cr-00007-TSE Document 17 Filed 01/05/11 Page 2 of 3

COUNT ONE

(Interstate Threatening Communications)

THE GRAND JURY FURTHER CHARGES THAT:

1. The Grand Jury realleges and incorporates by reference the GENERAL

ALLEGATIONS of this Indictment.

2. Between on or about November 2010 and on or about December 5,2010, within the

Eastern District of Virginia the defendant, Awais Younis, also known as Sundullah "Sunny"

Ghilzai, knowingly and willfully did transmit in interstate and foreign commerce from Arlington,

Virginia to the State of Louisiana, a communication to K.D.'s Facebook page, containing a threat

to injure K.D. directly and indirectly by harming her father, specifically "BITCH I know what you

are up too and you better stop if you know what is good for you!!!!!.... that is the problem with

americans they cant leave well enough alone until something happends then they sit there

wondering why we dropped the twin towers like a bad habit hahaha. [I']m telling you right now

you are going to regret doing what you did. For your peace [I] hope what [I] am hearing is all lies.

... you should be nervous. [Y]ou pissed me off. [W]hen things happen it will be your fault, just

wait and see. [I]ts only a matter of time.... you want a reason to complain about me and my

people. [I] will give you one the only way to make things ok with me is to fear me.
Case 1:11-cr-00007-TSE Document 17 Filed 01/05/11 Page 3 of 3

[T]hat [I] will prove. GET READY!... .whats amatter spoiled brat are you scared?.... tell your
father to cancel work tomorrow.... "

(In violation of Title 18, United States Code, Section 875 (c).)

A TRUE BILL:
I'lrsuam totheE-Government Act,
llieoriginal of this pagehasbeenfiled
under seal in the Clerk's Office.

FOREPERSON OF THE GRAND JURY

Neil H. MacBride
United States Attorney

By:
Ronald L. Walutes, Jr
Assistant United States.